The Aircraft Certification Service Project Prioritization and Resource Management Standard Operating Procedure (SOP)—or sequencing program—is meant to help the agency maximize its resources.

The program, launched in 2005, is taking on added importance as workload grows and FAA’s resources shrink.

The FAA’s Aviation Safety branch—which handles all certification—has lost about 350 staffers this fiscal year due to attrition and a hiring freeze.

This reduction in staff has forced the agency to pay special attention to how it allocates staff, especially on new projects such as part certifications or supplemental type certificates for modifications.

While the sequencing prioritization process is detailed, the implications are straightforward: If a non-critical project is expected to require more resources than the FAA can dedicate in a set period of time, it may be set aside completely.

The Modification and Replacement Parts Association (Marpa) says FAA’s effort to update the SOP, published last month in draft form for public comment, falls short on several fronts.

For instance, the FAA gives priority to projects that use the FAA’s designee program. Under the program, known as Organization Designation Authorization (ODA), companies set up a mini-organization—or hire ODA specialists—to verify compliance with milestones on a project that needs FAA approval. Progress is reported to the FAA, which verifies the work.

Marpa, in comments on the draft SOP, argues that the costs and resource requirements of establishing or hiring an ODA inherently favor larger companies.

The association also balks at the FAA’s proposal to place a higher “safety value” on new type certificates or modifications that would be incorporated into a production line.

Such logic means that identical proposals from a manufacturer and independent supplier—such as a parts manufacturer—to supply product to the aftermarket would not be treated equally, simply because the OEM can also work the upgrade into its production line.

“This places the independent competitor at an unfair disadvantage (having to wait longer for resources), that is not warranted by any safety rationale,” the industry group argues.